AXA : Rapport de transparence fiscale 2023

Tax Transparency Report

Tax Year 2023

Published in June 2024

With more than €11Bn in tax contribution to society in 2023, AXA performance is at the service of shared value. AXA recently unveiled its 2024- 2026 "Unlock the Future" strategy in which commitment is one of its three pillars: the Group will continue to play a responsible role in society.

THOMAS BUBERL

AXA Group Chief Executive Officer

CONTENTS

INTRODUCTION	3
Welcome	3
2023 Tax environment	4 - 5
GROUP TAX POLICY	6
Our Tax commitments	7
Tax risk management and internal governance	8
Tax aspects in relation to AXA as a multinational company	9
Tax aspects of the Group's activities	10
Tax aspects of products offered by the Group	11
TRANSFER PRICING	12
Clarifying key concepts	13
AXA locations worldwide	14
AXA presence in low-tax countries and EU black/grey lists at year end 2023	15
TOTAL TAX CONTRIBUTION	16
Total tax contribution by tax category	17
Total tax contribution by flagship country	18
IFRS corporate income tax figures - Clarifying key concepts	19
IFRS corporate income tax figures - 2023 Breakdown	20
Main other taxes by flagship country	21
COUNTRY-BY-COUNTRY INFORMATION	22
Country-by-Country Report - Clarifying key concepts	23
Glossary	24
AXA 2023 Country-by-country information	25 - 28

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AXA Tax Transparency Report - Tax Year 2023

INTRODUCTION

AXA GROUP TAX POLICY

TRANSFER PRICING

TOTAL TAX CONTRIBUTION

COUNTRY-BY-COUNTRY INFORMATION

WELCOME

I am pleased to present the sixth edition of the Tax Transparency Report for AXA Group. In this report, we provide insight into our tax strategy, highlighting the key principles that guide our approach to tax. We also give an overview of the Total Tax Contribution of the Group as well as outline our Country-by-Country reporting (CbCR).

At AXA, we recognize the vital role taxes play in contributing to the societies in which we operate. We firmly believe that paying taxes not only fulfills our legal obligations, but also serves a crucial role in supporting public services, infrastructures and social welfare programs. This report reflects our dedication to fostering trust and sustainable value creation through responsible tax practices.

As a multinational operating in many countries, AXA is committed to taking its responsibility to pay its fair share of taxes to the countries where it is does business. The Group is committed to being a responsible taxpayer that works closely and continuously with experts, auditors and tax authorities to consider both the letter and the spirit of the law and to ensure it pays the right amount of taxes in the right place and at the right time. AXA's tax commitment precludes the use of any non-cooperative jurisdictions to avoid taxes on any activities performed elsewhere.

In 2023, AXA had a total tax contribution of more than 11 billion euros. This contribution, which goes beyond corporate income tax, is composed of the amounts the Group owed directly on its operations and the amounts it collects on behalf of local tax authorities.

In the current challenging landscape of evolving tax regulations and reporting requirements, we are actively monitoring and adapting to changes, particularly with the implementation of the global minimum tax under Pillar 2 due to go into effect in France on January 1st , 2024.

We acknowledge that tax is a complex evolving area and therefore welcome your thoughts and questions on the content of this report, as we pursue our ambition towards greater tax transparency.

ALBAN DE MAILLY NESLE

Group Chief Financial Officer

Member of the Group

Management Committee

€11BN

2023 Group Activity Highlights

Despite the significant increase in overall risks, in 2023 AXA once again demonstrated its strength, dynamism, and the relevance of its purpose: to "Act for human progress by

protecting what matters".

2023 also marks the end of a strategic cycle for AXA with the closure of our "Driving Progress 2023" plan and the completion of an intense transformation.

Over the past few years, the Group has undertaken a significant refocusing on technical risks, built its global leadership in large corporate risks through the acquisition of XL, and strengthened its positions in high-potential markets.

In 2023, AXA also reinforced its presence in Europe upon completing the acquisition of the Spanish activities of Groupe Assurances du Crédit Mutuel and of Laya Healthcare Limited, a leading insurer in the Irish health market.

Building on these solid results, we unveiled our new "Unlock the Future" plan in early 2024 setting AXA's strategic priorities up to 2026.

of total tax contribution in 2023

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AXA Tax Transparency Report - Tax Year 2023

INTRODUCTION

AXA GROUP TAX POLICY

TRANSFER PRICING

TOTAL TAX CONTRIBUTION

COUNTRY-BY-COUNTRY INFORMATION

2023 Tax Environment

In 2023, the global tax environment continued to change in response to various initiatives in the European Union, domestic tax reforms in countries where AXA operates, and the implementation of the OECD Pillar 2 initiative (see page 5). Furthermore, the unstable political environment and the increasing requirements of tax administrations around the world gave rise to complex challenges for Multinational companies like AXA.

The European Union introduced or proposed several significant tax measures for corporations that reflect the EU's ongoing commitment to enhancing tax transparency and ensuring fair taxation across countries.

These primary measures are:

• OECD BEPS 2.0 - the introduction of a 15% global minimum tax rate: (see details page 5);
• Business in Europe: Framework for Income Taxation (BEFIT) proposal to introduce a common system to compute the tax base of multinational companies across the EU;
• Anti-AvoidanceDirective (ATAD) amendments that include stricter rules on hybrid mismatches, controlled foreign company (CFC) rules, and interest limitation rules;
• Debt Equity Bias Reduction Allowance (DEBRA) proposal to address the tax-induced bias favoring debt over equity financing by providing a tax deduction for increases of equity;
• Directive Facilitation Access to Services of Taxpayers in the European Region (FASTER) project to simplify and harmonize tax procedures across EU member states;
• Foreign Subsidies Regulation (FSR) entry into force, a new regime dedicated to preventing foreign subsidiaries from distorting competition on the EU market.

In France, following its introduction in the 2021 Finance bill and the modification of the scope of the VAT cost sharing exemption (Article 261B of the French tax Code), the first AXA VAT Group was put in place on January 1st,2023. The VAT Grouping is optional and once elected, it is in place for at least a 3-year period.

In the rest of the World, the main new tax measures that impacted the AXA Group were the enactment of a corporate income tax in Bermuda (see insert) and the adoption of the Qualified Domestic Minimum Top-UpTax subsequent to the introduction of the OECD Pillar 2 Minimum Tax in several countries where AXA operates (see details page 5).

Focus on Bermuda - Corporate Income Tax Enactment

On December 27, 2023, the Bermuda Corporate Income Tax Act 2023 was enacted. The CIT's primary provisions:

• Go into effect for fiscal years beginning on or after January 1st, 2025;
• Apply to Bermuda-based Multinational Enterprises (MNEs) with an annual revenue of €750 million or more in at least two of the four preceding fiscal years;
• Base the corporate income tax at 15%, subject to reductions for foreign tax credits;
• Introduce an economic transition adjustment (ETA) to allow for an increase or decrease in the tax basis of the assets and liabilities (excluding goodwill), held as September 30, 2023, to fair value.
• Provide for an opening tax loss carryforward based on amounts generated after September 30, 2023, unless an entity elects to disregard the ETA. If so, the statute provides for the net losses incurred in the five fiscal years preceding the effective date to be carried forward. Tax losses can be carried forward indefinitely.
• • AXA considered disregarding the ETA and therefore booked a €142m deferred tax asset in 2023 accounts based on the net tax losses carryforward

from the 2020-2024 period.

Starting fiscal year 2025, the AXA XL entities that are tax residents in Bermuda, will be subject to this new 15% corporate income tax.

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AXA Tax Transparency Report - Tax Year 2023

INTRODUCTION

AXA GROUP TAX POLICY

TRANSFER PRICING

TOTAL TAX CONTRIBUTION

COUNTRY-BY-COUNTRY INFORMATION

2023 Tax Environment - OECD Pillar 2 Minimum tax

In 2023, many countries where AXA operates enacted the OECD Pillar 2 minimum tax into their domestic law. Indeed, members of the European Union had until the end of the year to transpose the EU directive into their domestic law. In addition, countries like the United Kingdom, Switzerland or Hong Kong also passed similar laws for application in 2024 or 2025. It is to be noted that the United States and China currently have no plan to introduce this minimum tax. As to the US this mainly stems from their "GILTI" legislation that provides for a minimum tax on foreign income.

The minimum tax under Pillar 2, also known as the "Global Anti-Base Erosion" (GloBE), establishes a coordinated set of rules to ensure that multinational enterprises (MNEs) pay a minimum level of tax on their profits, regardless of where these profits are generated. These rule thus prevent MNEs from shifting profits to low-tax geographies and ensure they pay their fair share of taxes in the jurisdictions where they generated profit.

The global minimum tax consists of :

• the Income Inclusion Rule (IIR) top-up tax that imposes a top-up tax on the ultimate parent entity of a low-taxed foreign subsidiary and;
• the Undertaxed Payment Rules (UTPR), secondary taxing rules that are designed to operate as a backstop to the IIR top-up-tax if the ultimate parent company is located in a jurisdiction where Pillar 2 has yet to be implemented. In France, AXA SA, the ultimate parent company, will be subject to the IIR top-uptax.

Regulatory updates

• The OECD Model Rules, published on Dec 20, 2021, have to date been completed by administrative guidance in 2022, 2023 and 2024. On Dec 16, 2022, the EU minimum tax Directive was issued.
• France adopted the Directive and implemented it on December 21, 2023. Theses rules apply to the fiscal years beginning on or after Dec 31, 2023.
• Accordingly, this new regulation is mandatory for AXA SA (the parent company of the AXA Group) starting January 1, 2024. The tax return for 2024 must be filed by June 30, 2026.
• Many countries where AXA operates have already enacted a Qualified Domestic Minimum Top-Up Tax (QDMTT). When fully compliant with OECD rules, the domestic QDMTT will trigger some additional local tax instead of the IIR top-up tax at the level of the ultimate parent.

Where do we stand at AXA ?

Throughout 2023, AXA Group Tax experts, along with other AXA Group accounting, data and IT experts, continued to carefully assess the impact of the minimum tax for the Group and to ensure its readiness. Project updates were regularly shared with the entities and auditors.

As required under the IAS12 amendment, AXA disclosed in its 2023 consolidated financial statement that, based on ongoing analysis, Ireland, Hong Kong and Bermuda were the main jurisdictions where the group might have an exposure (see note 1 "accounting principles"). As to Bermuda, because of the implementation of Corporate Income tax in 2025, the Bermuda profits that will be realized in 2024 will give rise to a top-up tax in France.

For 2024, based on AXA Group's projected results (which will be subject to refinement), the estimated amount disclosed in note 1 was €0.1 billion.

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AXA Tax Transparency Report - Tax Year 2023

AXA Group Tax Policy is available here

INTRODUCTION

AXA GROUP TAX POLICY

TRANSFER PRICING

TOTAL TAX CONTRIBUTION

COUNTRY-BY-COUNTRY INFORMATION

Being a responsible taxpayer

Our commitments

ESG criteria

C	CONTRIBUTE by paying our taxes at the right time and at the right place
O	OPERATE as a transparent and collaborative partner with tax authorities and states

M	MANAGE our tax organization to ensure full compliance
M	MONITOR our limited risk appetite through an adequate governance and appropriate processes

I	INCLUDE tax as a key contributor to ESG Group policy
T	TESTIFY to transfer pricing compliance with taxation of profits where activities are performed

Environnemental

Social

Governance

As an insurer, we are generally neither subject to environmental taxes (like the carbon or plastic tax) nor a beneficiary of green subsidies or incentives. Being immaterial, these constitute no part of the total tax contribution for the Group.

With around 114,000 AXA employees worldwide, the total social charges borne both by AXA employees and AXA as an employer amounted to €2.5bn in 2023. AXA is committed to paying its fair share of tax to contribute to the financing means of the countries where it operates.

At AXA, in accordance with the Group Management Committee, we have implemented several Group level processes (Internal Control Framework, Group Tax Policy, Tax Code of Ethics,…) to make sure we have the right monitoring on tax topics and to ensure tax risks are appropriately identified and managed.

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AXA Tax Transparency Report - Tax Year 2023

INTRODUCTION

AXA GROUP TAX POLICY

TRANSFER PRICING

TOTAL TAX CONTRIBUTION

COUNTRY-BY-COUNTRY INFORMATION

Tax risk management and internal governance

The Group Tax Department of the AXA Group is part of the central Finance function and is therefore under the responsibility of the Group Chief Financial Officer. It is led by the Group Head of Tax who directly and regularly reports to the Group Chief Financial Officer to keep him abreast of tax-related matters.

The Group Tax Department is accountable and responsible for the Group's:

• tax positions and group-level tax strategy
• tax policies, controls, and instructions
• global transfer pricing model

The local entities' tax teams are accountable and responsible for tax compliance and the day-to-day tax matters under the Group Tax Department's guidance.

AXA Group has a strong corporate tax Governance inspired by the best existing standards (GRI, B-Team Principles…) as laid out in the AXA Group Tax Policy. This Policy is validated annually by the Group CEO and published in the Universal Registration Document. We consider tax risk management fundamental to maintaining efficient and effective operations, as well as to ensuring full compliance with tax regulations.

Government authorities may offer tax incentives to support business sectors, create employment or foster their economic development. AXA carefully considers these incentives and only claims those that are aligned with our business operations and fit with our investment or business strategy. We refrain from discretionary tax arrangements.

In addition, the current AXA Group whistleblowing procedure allows all stakeholders (employees, business partners, etc. ) to share their concerns without any delay and/or to report any practice, action, or behaviour that they consider inappropriate, illegal, or unethical ([e-mail]).

To ensure effective tax risk management, a number of measures and processes are in place throughout the Group to identify, assess and monitor tax risks such as :

• Handling tax-related topics by highly qualified in-housetax experts who are provided with ongoing training and access to external advice when needed
• Ensuring consistent practices on technical matters as well as adherence to guidelines pertaining to tax risks and tax audits. An International Tax Committee and an International Tax conference gather various senior tax executives throughout the different entities of the Group. The last conference held in September 2023.
• Implementing a uniform and well-establishedreporting of the uncertain tax positions the local entities regularly provide to the Group Tax Department
• Monitoring changes in tax laws and their impacts on AXA and the industry
• Updating the Group Audit Committee of the Board of Directors on the significant tax risks on a regular basis (last update in December 2023)
• Including internal controls on tax processes in the Group's internal finance control program and operational risk process
• Maintaining a limited tax risk appetite through efficient controls and external advice, when needed
• Seeking, when necessary, certainty in advance from tax authorities to confirm an applicable tax treatment based on full disclosure of all relevant facts and circumstances
• Defining Group standards for tax compliance, and ensuring their full satisfaction, particularly for cross-borderlife business, and more globally for compliance with tax regulations

The Group is additionally actively involved in tax regulation discussions through its membership in various national and international business and insurance associations in the countries where it operates. These memberships allow the Group to ensure an ongoing transparent exchange on tax-related matters with a variety of stakeholders.

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AXA Tax Transparency Report - Tax Year 2023

INTRODUCTION

AXA GROUP TAX POLICY

TRANSFER PRICING

TOTAL TAX CONTRIBUTION

COUNTRY-BY-COUNTRY INFORMATION

Tax aspects in relation to AXA as a multinational company

In the countries where it operates, AXA is both a taxpayer and a tax collector, given that many specific taxes are levied on insurance and reinsurance policies and collected from our customers as part of the insurance and reinsurance revenues while others are remitted to the various state and federal administrations around the world.

The tax function is organized within the Group to ensure full compliance with all tax legislation in the countries where AXA operates. In addition to the Group Tax Department based in France, all key operational entities/countries/geographic zones have a tax team in charge of ensuring that tax regulations are well understood and satisfied by the entities.

As part of the global internal risk assessment, a specific tax internal control program is implemented. These controls must be reported and documented by each team in scope to ensure full compliance.

A Tax Code of Ethics, agreed between the Group Tax Department and local tax teams, highlights the key principles guiding the actions of the various tax teams:

• to remain up to date with respect to applicable laws and regulations;
• to comply with tax laws and regulations;
• to maintain a good relationship with the local tax authorities and, when possible, to adhere to cooperative compliance programs or similar initiatives depending countries and;
• not to engage in aggressive tax-driven transactions that could compromise the good reputation of the Group.

The satisfaction of this Code of Ethics is a prerequisite of the activities performed by all AXA tax teams and gives rise to a formal annual certification by each head of tax, which is provided to the Group tax team. ln addition, a bi-annual tax review process of each key entity or business line is performed by the Group Tax Department in connection with each local team. During these reviews, specific attention is given to tax audits and associated tax risks as well as market positions on tax matters that may impact AXA. These reviews offer a global framework for the tax teams to identify, analyze, control, and report tax risks.

Lastly, an International Tax Committee composed of various senior tax executives within AXA tax teams meets every quarter to ensure consistency in approach on some technical topics, as well as agreements on guidelines, when necessary, connected to specific items.

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AXA Tax Transparency Report - Tax Year 2023

INTRODUCTION

AXA GROUP TAX POLICY

TRANSFER PRICING

TOTAL TAX CONTRIBUTION

COUNTRY-BY-COUNTRY INFORMATION

Tax aspects of the Group's activities

The Group's activities are subject to strict regulations and rigorous control in each territory in which AXA operates. ln addition to these regulations, AXA has developed a set of detailed internal standards that applies to all Group entities that are managed or controlled by AXA, regardless of the activities undertaken by the entity or its ownership structure.

According to these internal standards, Chief Executive

Officers must ensure that staff are fully conversant, and comply with applicable laws, mandatory Codes of Conduct, rules and regulations (including applicable tax laws and regulations) relevant to their area of operations.

This means that local senior management must appreciate the tax implications of the activities in their entity.

The main considerations are:

• compliance with the taxation of employees in the territory in which they are employed;
• compliance with the taxation of business undertaken in the territory (including levies and sales taxes); and cross-border tax issues.

A specific focus on transfer pricing is made in application of these standards, to ensure that the pricing of our intragroup activities is consistent with the OECD "arm's length" principle as well as with local transfer pricing rules to pay adequate tax on profits where the value is created.

ln particular, Chief Financial Officers must ensure that insurance and reinsurance policies entered into represent a true transfer of risk and that their status as insurance or reinsurance contracts could not be subject to challenge.

Business between Group companies must be transacted at market prices where a market price exists, or in the absence of market prices, must be supported by formally documented justification for the charge made.

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AXA Tax Transparency Report - Tax Year 2023